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Suspicious Activity Report Leads to Embargo Investigation

An investigation of a possible violation of the International Emergency Economic Powers Act was initiated following a SAR filing by a bank in New York. The SAR stated that an unnamed bank vice president in charge of the funds transfer program manipulated four payments to the Sudan totaling $73,000 in violation of the embargo. The subject allegedly manipulated the bank’s internal Office of Foreign Assets Control (OFAC) filtering system by either manually overriding its screening and blocking function or by omitting any reference to Sudan and reprocessing the wire transfers through the same filtering system. The case was turned over to OFAC.

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